In Brief
K.K. Mishra, a Congress spokesperson, faced defamation charges under Section 500 IPC for statements made at a press conference alleging nepotism by the Chief Minister of Madhya Pradesh. The Supreme Court quashed the prosecution and conviction, holding that the allegedly defamatory statements—concerning appointment of persons from the Chief Minister's in-laws' area and phone calls by his relatives—had no reasonable nexus with the discharge of public duties. The Court found the Public Prosecutor had failed to independently scrutinize materials before filing the complaint under Section 199(2) CrPC, merely following government orders. Where statements lack nexus with official functions, the special procedure under Section 199(2)-(4) is unavailable; the ordinary private complaint remedy under Section 199(6) applies instead.
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